Last updated: 21st September 2022
HornClaw Studio Private Limited (hereinafter referred to as “HornClaw” or “We” or “Us” or “Our”, as the context requires) owns and operates a cricket-inspired trading game where users can buy/sell stox of real-life cricketers through the portal called ‘CricStox’ which shall be made available as a website and/or mobile application (each a “Platform”). For the purpose of this Privacy Policy, references to Platform will also include the usage of our website, services, applications, products and content by you.
We are committed to complying with the applicable privacy laws. Protecting the privacy and security of your personal data is of prime importance to us, therefore, we conduct our business by abiding by the laws applicable to data privacy and data security in the country where the Platform operates.
This Privacy Policy explains how we collect, use and share your personal information when you use the Platform (which includes our websites, stores, apps, digital content etc.).
By accessing our Platform, you agree, acknowledge, and grant your consent for the collection, use, storage, and transfer of your information in terms of this Privacy Policy and agree to be bound by the terms and conditions of this Privacy Policy. You hereby expressly consent to the processing of your personal information in accordance with this Privacy Policy.
Your information may be stored, processed or transmitted in India or any other part of the world, where laws regarding storing, processing or transmitting of personal information may be less restrictive than the laws in your country. We do not sell/ trade your personally identifiable information; however, we may share the same with third parties who assist us in conducting our business, operating our Platform, or servicing you, so long as those parties agree to keep this information confidential. You expressly agree to us sharing such information with third parties.
You always have the option to not provide information by choosing appropriate options/ choices available on our Platform; however, please note that in case you choose not to provide us with your information, you will not be entitled to participate in the services that our Platform offers.
I. TYPE OF INFORMATION WE COLLECT
We collect personal, sensitive, and other information from you in a variety of ways when you use our Platform. The information about you is collected by us as (i) information supplied by you and (ii) information automatically tracked during your navigation on our Platform.
User Account
a. We collect, and associate with your user account information like your name, age, birth date, state of residence, email address, username, password, social media login details, official ID identification such as PAN card, phone number, profile details, photographs including your photograph on your PAN card, details posted by you in respect of a contest, entries submitted by you for a contest, gender and other personally identifiable information. In addition, such information may include the comments or reviews you make on our Platform. If you create an account by logging in with your credentials from your third-party account with certain social networking sites (such as Twitter, LinkedIn, Google or Facebook), we may receive information about you from such social networking sites, in accordance with the terms of use and privacy policy of that social networking site. This data will include information relating to your use of the Platform on such public forums and/or social networks
b. We may also collect Sensitive Personal Information (“SPI”) from you on the Portal. SPI shall mean such personal information which consists of information relating to your physical, physiological, and mental health condition; medical records and history; biometric information, sexual orientation and financial information, such as information regarding the payment instrument/modes used by you to make such payments, which may include cardholder name, credit/debit card number (in encrypted form) with an expiration date, banking details such as bank account number, bank name and branch, IFSC code, wallet details etc., as well as your bank account statements/ cancelled cheque, if provided by you. This information is presented to you at the time of making a payment to enable you to complete your payment expeditiously.
c. We work with such social networking site applications in a way that allows you to authorize us to access your account on that social networking site on your behalf. If you consent to our sharing of your information with these social networking sites (e.g., post public content on your wall/profile page), we will share your information with them in accordance with your privacy choices. Once we share your information with these social networking sites, the terms and policies of these sites, and not our Privacy Policy, will apply to their use of your information. We encourage you to read the individual terms of use and the privacy policy of each of these websites before using them and/or disclosing your personal information.
d. When you visit our Platform, certain information may be collected automatically, which includes:
i. Your computer’s Internet Protocol (IP) Address,
ii. Your browser type and operating system,
iii. Web pages and links, you visit, advertisements you view, your browsing history (including content you have posted, uploaded and viewed on the Platform),
iv. Your bandwidth speed and information about the software programs that are installed on your computer,
v. Standard server log information,
vi. Your mobile service provider, mobile or device information including the model of your device, your screen resolution, time zone settings, location data, GPS data, and
vii. Any other information regarding your use of the Platform.
You can change the location settings on your mobile device if you do not wish to share your location information with us.
Platform Use Related
When you use our Platform, we store, process, and transmit your files (like feedback, log file information from the browser, software etc., keywords, metadata (including how your content was collected or formatted) and other data) and information related to them. If you give us access to your contacts, we’ll store those contacts on our servers for you to use. This will make it easy for you to do things like sharing your data, sending emails and inviting others to use our Platform using your email or social media log-in details. We collect engagement scores and related users. Finally, we collect opt-ins and communication preferences.
Surveys
We may occasionally ask you to complete optional online surveys/ feedback forms. These surveys/ forms may ask you for contact information, geographic information and demographic information (like postal codes, age, income level, lifestyle etc.). We use this data to tailor your experience at our Platform, providing you with content that we think you might be interested in and displaying the content according to your preferences.
Your phone and Facebook & Telegram contacts
You can choose to find users of the Platform either through (i) your phone contacts or (ii) Facebook contacts or (iii) Telegram contacts. If you chose to find such users through your phone contacts, you are providing us access to your phone contacts, using which we will collect your phone contacts, including the names, phone numbers, addresses and any other information that you have stored on your phone about your contacts in order to determine if they are using the Platform by matching them with existing users of the Platform. If you want to find other users through your Facebook contacts or Telegram contacts, we will collect your public Facebook information as well as the names and profiles of your Facebook contacts, and the username and numbers of your telegram contacts.
Messages
We collect and process the information you provide, including any personal information, in the context of composing, sending, or receiving messages (that means the content as well as information about when the message has been sent, received and/or read and the participants of the communication) through our Platform’s messaging functionality. Please be aware that messages sent to other users of our Platform will be accessible by those other users and that we are not responsible for the manner in which those users use or disclose messages.
Cookies and other technologies
We use technologies like cookies to provide, improve, protect, and promote our Platform. For example, cookies help us with things like remembering your login details, name, and preferences for your next visit, understanding how you are interacting with our Platform, and improving it based on that information. We may use software tools to collect information about how you interact with our Platform, such as mouse clicks, drags, hover-overs, response times, errors, length of visits to certain pages, server details and IP addresses. You can set your browser to not accept cookies, but this may limit your ability to use and experience our Platform. We may ask our other partners to serve services to your devices, which may use cookies or similar technologies placed by us or a third party. We do not control the use of such technologies used by advertisers and partners and we expressly disclaim responsibility for information collected by them.
Analytics Services
We may use third-party services, to collect information about how you use and interact with our Platform. Such third-party analytics services may use cookies to gather information such as the pages you visited, your IP address, a date/ time stamp of your visit and which site referred you to our Platform. We use these analytics services to help us analyze how people use our Platform, improve them, customize the content/ features users see/ use based on their interests and send emails to users who are not actively using our Platform. For more information about how these entities use this information, please refer to their privacy policies made available on their websites.
Third Parties
We may receive information about you from third parties that offer their products and/ or services on our Platform. These third parties may supply us with your information. We may add this information to the information we have already collected from you via our Platform in order to improve the Platform.
Other Information
We may also collect other sensitive personal data or information as included in Rule 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
Please note that information about you shall not be considered to be sensitive or personal or private if it is freely available in the public domain or under the right to information laws or under any other applicable law for the time being in force.
II. HOW WE USE YOUR INFORMATION
General
We may use the information collected from you to register you or your device for a service, to provide a service or feature you request, to allow other users to identify you via the “Find Friends” function, to allow you to find other users and to connect with them on the Platform, and to support the socializing function of the Platform, to make your information available to other users in accordance with the privacy settings you chose for the respective information, to assist us in detecting abuse, fraud or illegal activity on our Platform.
Advertisements
We may use your information to provide you with updates about new features introduced on the Platform, updates about new brands, products or services, newsletters and other communications about existing and/or new products and services by post, email, telephone, in-device messaging and/or text message (SMS), if you have provided your prior consent or we are otherwise permitted to do so under applicable law. We may further use the content uploaded/ broadcasted by you to promote our Platform.
Statistics and Research
We may use your information to create user group profiles or segment data and to otherwise create anonymous, aggregated statistics about the use of our Platform and loyalty programs, which we may share with 3rd (third) parties and/or make available to the public.
Improvement
We may use your information to administer, analyze, improve and enhance the Platform and develop new features, for conducting data analysis, making recommendations, advertisements and other communications and learning more about customers’ preferences in general. We may use the information to introduce interactive features to the Platform, and personalize the content you will receive basis your preferences, behavioural pattern or geographical location.
Publish your entries, reviews, and content
Where you have submitted your entries for the contests, posted reviews (in relation to our Platform), comments or any other content to our Platform and made them publicly visible, we may link to, publish, or publicize these materials elsewhere including in our own advertisements. Please note that any personal information you submit while posting such reviews, comments or content can be read, collected, or used by other users. We are not responsible for the information you choose to submit on the Platform or if you receive any unsolicited communication due to such information provided by you.
III. HOW WE SHARE YOUR INFORMATION
We may share your information as per terms of this Privacy Policy; however, we shall endeavour that such use of information does not create a hindrance to your use of our Platform. We do not share your information with third parties other than as follows:
Internally
We may share your information with our agents, contractors or third-party service providers who provide administrative, telecommunications, computer, payment, securities clearing or other services to us in connection with our Platform or the operation of our business.
Others working with us
We use certain trusted third parties to help us provide, improve, protect, and promote Platform (such as third-party analytics tools to help us measure traffic and usage trends for our Platform). We may share the information with (i) entities providing cloud storage to use for storing the information you provide and for disaster recovery services, (ii) analytics and search engine providers that assist us in the improvement of the Platform; and (iii) data centre and the servers of our host providers. These third parties will access your information only to perform tasks on our behalf and in compliance with this Privacy Policy. We may also share statistical data and other details (other than your personal information) without your express or implied consent to facilitate various programmes or initiatives launched by us, our affiliates, agents, third-party service providers, partners, or banks & financial institutions, from time to time. We may also share your data with companies/ brand owners who are registered on our Platform.
Third Parties
We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.
Generally, with your consent
Any information or content that you voluntarily disclose for uploading/ broadcasting any content on our Platform and becomes available to the public, is controlled by any applicable privacy settings that you set. To change your privacy settings on our Platform, you may change your profile settings. Once you have shared the content/data with any person or made it public, that content/ data may be re-shared by others.
Structural Changes
We may share some or all of your information in connection with or during the negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your information may also be transferred as a business asset. If another entity acquires us or our business or assets, that entity will possess all your information collected by us and will assume the rights and obligations regarding your information as described in this Privacy Policy.
Enforcing Rights
We may also disclose personal information to enforce our policies, respond to claims that certain content violates others' rights, or protects anyone’s rights, property, or safety.
Law & Order
We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with the laws; (b) detect, prevent, or otherwise address security, fraud, or technical issues; or (c) prevent fraud or abuse of our name, brands, trademarks, or such other rights belonging to us or our other users.
IV. STORING OF INFORMATION
Security
We have a team dedicated to keeping your information secure and testing for vulnerabilities. We also continue to work on features to keep your information safe in addition to things like alerts when new devices and apps are linked to your account.
We have appropriate safeguards, including physical and managerial procedures and technical measures, warnings, and firewalls, to protect against the loss, misuse, and alteration of any customer information under our control. Our servers are accessible only to authorized personnel. For example, we encrypt your passwords and bank account/ credit card information when you transmit them to us. However, we will treat any communication or material you transmit to the Platform by electronic mail or otherwise, that is not personally identifiable information as non-confidential and non-proprietary. Such communications or materials include, without limitation, questions or answers, comments, feedback, and suggestions.
Although we deploy the security standards as per industry practice to safeguard the confidentiality of your personally identifiable information, you acknowledge that transmissions made by means of the internet, computer system or wireless connection cannot be made absolutely secure. Hence, our responsibility for maintaining your information shall be on a best-effort basis only.
HornClaw seeks to ensure compliance with the requirements of the Information Technology Act, 2000 and the rules framed thereunder to ensure the protection and preservation of your privacy. However, we will have no liability for disclosure of your information due to errors in transmission or unauthorized acts of third parties.
Retention
We will retain your personal information for as long as we need to enforce our contractual and legal rights and obligations or to retain backup/ archives.
No warranty
We use commercially reasonable safeguards to help keep the information collected through our Platform secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account; however, we cannot ensure or guarantee the security of any information you transmit to us or guarantee that information on our Platform may not be accessed, disclosed, altered, or destroyed by any person.
Around the world
To provide you with our Platform, we may store, process and transmit information in locations around the world - including those outside your country. Information may also be stored locally on the devices you use to access our Platform. By registering for and using our Platform, you consent to the transfer of information to any part of the world in which we, our affiliates or service providers maintain facilities and the use and disclosure of information about you thereto as described in this Privacy Policy.
V. GENERAL TERMS IN RESPECT OF INFORMATION
If you upload/ broadcast any content including comments, reviews or messages onto the Platform for the first time, you will be notified that it can be viewed by every user of the Platform regardless of your connection to the user. You can limit the audience having access to the information that you post to the Platform in your privacy settings. Please note that changes to the privacy settings on the Platform will immediately apply and also affect information that you have posted in the past. The content uploaded/ broadcasted by you will be deleted once you decide to delete the respective content from your profile.
If any personal information or sensitive personal data or information provided by you is found to be inaccurate or deficient, then the same shall be immediately corrected or amended by you. To attain this end, you will be granted reasonable access to such information, or you may request us to update your information by emailing the request/clarification at connect@cricstox.in. We may however before processing such requests, ask you to identify yourself and the information/data requested to be modified by you in order to avoid repetitive and/or illegitimate requests. We shall not be responsible for any delay in updating such information. Please note that we will not be responsible for the authenticity of the personal information or sensitive personal data, or information supplied by you.
You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and us, at all times. We are not responsible for any third-party functionality, privacy or security policies, to which you are bound. In the event you believe that your information has been stolen or compromised, you must contact us immediately at connect@cricstox.in. We will endeavour to block your account or provide restricted access upon being informed of such an event in order to protect your identity and information. However, we shall not be responsible for any unauthorized use/access to your account or disclosure of any personal information by virtue of such an event.
The uploading, dealing, handling and/ or using of any information for any lawful purpose by us, including for the purposes and in the manner outlined above shall not constitute ‘publication’ in any manner.
The Platform is not directed at children under the age of 18 (Eighteen) years. If we become aware that personal information has been collected from a person under the age of 18 (Eighteen) years, we will delete this information and terminate the person’s account. If you believe that we have collected information from a child under the age of 18 (Eighteen) years, please contact us at connect@cricstox.in.
VI. LINKS TO OTHER WEBSITES
The Platform may contain links to other websites and/ or applications that we do not own or control. Our Privacy Policy does not apply to these websites/ applications. We are not responsible for the privacy practices or the content of other websites or applications. Such content is subject to their terms of use and any additional guidelines and privacy information provided in relation to that use on their website. We recommend that you check the policy of each website/ application you visit to better understand your rights and obligations especially when you are submitting any type of content on those 3rd (third) party websites/ applications. Please contact the owner or operator of such a website/ application if you have any concerns or questions.
Please note that displaying advertisements or links does not tantamount to our endorsement or promotion of the products, services or brands offered by such third parties.
VII. CHANGES TO THE PRIVACY POLICY
We may change this Privacy Policy from time to time. If we make any changes to this Privacy Policy, the last modified Privacy Policy shall be applicable to you. We shall not be required to notify you, whether as a registered user or not, of any changes made to the Privacy Policy. Any such modifications will become effective immediately upon posting to the Platform and you shall be solely responsible for reviewing and becoming familiar with any such modifications.
VIII. COMMUNICATIONS
We may periodically send you free newsletters and promotional communications. When you receive newsletters or promotional communications from us, you may “unsubscribe” from these emails by following the unsubscribe instructions provided in the email you receive or by contacting us at connect@cricstox.in. Despite your indicated email preferences, we may send you notices of any updates to our Privacy Policy, Terms of Use or other administrative emails.
IX. CONTACT
Any queries and/ or concerns regarding this Privacy Policy or practices relating to this Platform should be directed to the attention of our Privacy Officer at info@cricstox.in.
